As further described herein, your personal information may be collected, processed and stored by Altus or its service providers in the United States and other countries where such servers reside. You hereby agree with and consent to the transfer of your personal information to the United States and other countries where we and our service providers operate.
You may have a legal right to withdraw your consent to Altus’s collection and processing of certain personal information, or to the transfer of your personal information across borders. To request to withdraw your consent, please contact us as set forth below.
THE INFORMATION WE COLLECT AT THIS SITE
We collect the following nonpublic personal information (“Personal Data”) directly from you through this Site:
We may combine the Personal Data you submit directly through the Site with other Personal Data we have collected from you, whether on- or offline. We may also combine it with information we receive about you from other sources, such as publicly available information sources and other third parties.
HOW WE USE THE INFORMATION WE COLLECT AT THIS SITE
We may use the anonymous information that we collect to improve the design and content of our Site and to enable us to personalize your Internet experience. We also may use this information in the aggregate to analyze Site usage. We may share certain anonymous information such as demographics and usage statistics with third parties to perform these functions. When this type of information is shared, the other parties do not have access to your PII. If we combine information that is not in personally identifiable form with information that is (such as combining your name with your geographical location), we will treat the combined information as Personal Data as long as it is combined.
We may use your Personal Data in other ways for which we provide specific notice at the time of collection.
COLLECTION OF INFORMATION BY THIRD-PARTY SITES
OUR COMMITMENT TO SECURITY
We have put in place physical, electronic, and managerial procedures as required by law and as we deem reasonable designed to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect through the Site. However, we cannot guarantee the security of any information that is disclosed online. Therefore, we make no warranty regarding the security of any information you transmit to us via the Site and you do so at your own risk.
In addition, we take reasonable steps to ensure that we retain your Personal Data for so long as is necessary for the purpose for which it was collected, or as required under any contract or by applicable law.
NO COLLECTION OF PERSONALLY IDENTIFIABLE INFORMATION FROM CHILDREN
The Site is not directed at children and we do not knowingly collect any PII from children under thirteen (13) years of age unless the collection complies with the Children's Online Privacy Protection Act ("COPPA"). If you are under thirteen (13) years of age, do not send any information about yourself to us. If we discover that a child under the age of 13 has provided us with PII, we will use commercially reasonable efforts to delete that child's PII from our system.
RESPONSE TO DO NOT TRACK SIGNALS
Some web browsers incorporate a “Do Not Track” (DNT) or similar feature that signals to digital devices that a visitor does not want to have his/her online activity tracked. Because not all web browsers offer DNT options and DNT signals are not yet uniform, we and many other digital service operators do not respond to DNT signals.
CALIFORNIA PRIVACY RIGHTS
Under California’s “Shine the Light Law”, California residents who provide Personal Data in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year.
To obtain this information on behalf of Altus, please send an email message to email@example.com with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your email address in the response. Please be aware that not all information is covered by the “Shine the Light “requirements and only information on covered sharing will be included in our response.
EU DATA SUBJECTS
In the European Economic Area and Switzerland (“EU”), “Personal Data” is defined very broadly and includes any information about a natural person, who can be identified, directly or indirectly, from data that we hold about them or from data that is combined with other information. EU data protection law requires us to have a legal basis before processing any Personal Data about you. The legal basis’ for us processing your Personal Data for the above purposes may be because: (i) you have provided your consent; (ii) it is necessary to for the performance of a contract with you; (iii) the processing is necessary for our compliance with a legal obligation; or (iv) the processing is in our legitimate interests. To the extent provided by applicable law, you may withdraw any consent you previously provided to us, or object at any time on legitimate grounds, to the processing of your Personal Data. In some circumstances, withdrawing your consent to Altus’s use or disclosure of your Personal Data will mean that you cannot take advantage of certain Altus products or services.
We may transfer your Personal Data outside the EU to the United States or any country that Altus or its service providers may have operations. Such countries do not have the same data protection laws as the EU. Any transfer of your Personal Data will be subject to a European Commission approved contract (as permitted under the General Data Protection Regulation) that is designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your Personal Data. To obtain a copy of the such safeguards please contact us.
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation (or other relevant guidance).
If you would like to exercise any of those rights, please Email, call, or write to us with the following:
HOW TO COMPLAIN
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the EU state where you work, normally live, or where any alleged infringement of data protection laws occurred.
YOUR CHOICES REGARDING YOUR INFORMATION
CAN AN INVESTOR OPT-OUT OF ALTUS COLLECTING PERSONAL DATA?
No, in that as an investor, you consented upon execution of the fund(s) subscription and related documentation; however, you may withdraw from the fund(s) as contracted, and therefore withdraw further consent. Users who wish to opt out of using the investor portal, accessed from Altus’s website, for accessing communications from Altus may do so by contacting us. Altus will provide documents to such investor through another method, such as first class postal delivery, as agreed with the investor. Investors who do not wish to review the Altus website do not have to visit or use the site.
Please note that in order to fulfill certain obligations, we may need to continue sending you notices or other important information concerning any orders or services you request. You should be aware that it is not always possible to completely remove or delete all of your information from our databases without some residual data because of backups and other reasons.
HOW TO CONTACT US
UPDATES & EFFECTIVE DATE
Altus reserves the right to disclose, share, assign and/or otherwise transfer your Personal Data, including without limitation PII, in connection with a merger, acquisition, consolidation, the sale of substantially all of its assets, or any other corporate transfer, exchange or restructuring, whatever form it may take. We may transfer information, including your Personal Data, in connection with a merger, sale, acquisition or other change of ownership or control by or of us or any affiliated company (in each case whether in whole or in part).